Industrial Policy & Trade Monitor· 2668 actions· ✨ 89 recent

On 2 September 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated Waleed Khaled Hameed al-Samarra'i, a dual Iraqi/St Kitts-and-Nevis citizen, along with his UAE-based shipping manager Babylon and five Marshall Islands-registered shell companies (Tryfo Navigation, Keely Shiptrade, Odiar Management, Panarea Marine, Topsail Shipholding) that hold registered ownership of nine Liberia-flagged tankers (ADENA, LILIANA, CAMILLA, DELFINA, BIANCA, ROBERTA, ALEXANDRA, BELLAGIO, PAOLA). The network blends Iranian crude with Iraqi oil via ship-to-ship transfers in the Arabian Gulf and at Iraqi ports, then markets the blend as solely Iraqi-origin to evade US sanctions, generating hundreds of millions of dollars for the Iranian regime and al-Samarra'i. The action was taken pursuant to Executive Order 13902 and blocks all US property and interests of the designated individual, entities and vessels.

The FCC adopted a Report and Order (FCC 25-49) on 7 August 2025 — the first comprehensive overhaul of submarine cable landing license rules since 2001 — effective 26 November 2025. The order prohibits Indefeasible Right of Use (IRU) agreements that would give entities from designated foreign adversary countries (China including Hong Kong and Macau, Cuba, Iran, DPRK, Russia, and Venezuela) control over Submarine Line Terminal Equipment (SLTE) on US cable landings, and mandates new annual reporting plus certification/disclosure requirements covering ownership, cybersecurity and physical security plans, and FCC Covered List compliance. The order operationalises the FCC's bifurcated policy package: accelerating legitimate commercial cable buildout while hardening national-security review for foreign-adversary-connected infrastructure.

On 30 April 2025 the US Department of State designated seven entities and identified two vessels as blocked property for facilitating trade in Iranian petroleum and petrochemical products, under Executive Order 13846 and in furtherance of National Security Presidential Memorandum 2 (NSPM-2, "Restoring Maximum Pressure on the Government of Iran"). The action named four UAE-based sellers and one purchaser of Iranian petrochemicals — including Solvent Organics (over $300 million in exports of Iranian-origin petrochemicals to third countries) and Alseerah Trading (over $150 million) — plus a Turkiye-based petrochemical trader, an Iran-based cargo inspection company, and a marine management company involved in transporting millions of barrels of Iranian crude. Secretary of State Marco Rubio stated the goal was to drive Iran's illicit oil and petrochemical exports, including to China, to zero.

President Trump signed Executive Order 14269 on 9 April 2025 (FR publication 15 April 2025), launching the first whole-of-government US shipbuilding and maritime industrial-policy instrument since the 1996 Maritime Security Program. The order directs development of an America's Maritime Action Plan (MAP) under APNSA leadership within 210 days (released 13 February 2026) and tasks DoD, DoT, DHS, Commerce, USTR, and OMB with a sequenced set of reviews covering deregulation of the domestic commercial maritime fleet, expansion of the Maritime Industrial Base, mariner workforce development, Maritime Prosperity Zones, and Office of Strategic Capital loan deployment to commercial shipyards. The EO is the cross-government industrial-policy umbrella; the simultaneously-developed USTR Section 301 China Maritime/Logistics/Shipbuilding action (filed 17 April 2025) is the China-specific tariff-track instrument.

On January 10, 2025, the US Treasury's Office of Foreign Assets Control (OFAC), acting jointly with the Department of State, designated PJSC Gazprom Neft and PJSC Surgutneftegas as Specially Designated Nationals (SDNs) under Executive Orders 13662 and 14024, alongside more than 180 oil-carrying vessels (the bulk of Russia's "shadow fleet"), dozens of opaque oil traders, two major Russia-based oilfield service providers, marine insurance companies, and senior Russian energy-sector officials. The package included a new EO 14024 sectoral determination authorizing future designations against any person operating in the Russian energy sector, plus a new EO 14071 determination prohibiting the provision of US petroleum services (extraction, drilling, production support) to persons located in the Russian Federation, effective 12:01 a.m. EST on February 27, 2025. OFAC simultaneously issued General Licenses 117 (wind-down of transactions with the newly blocked entities) and 118 (debt/equity/derivatives wind-down), both expiring February 27, 2025. The action was the largest single Russia energy-sector designation since the 2022 invasion regime began and was coordinated with parallel UK OFSI shadow-fleet designations issued the same week. The action was finalized in the closing days of the Biden administration as a deliberate tightening of the oil-revenue and shadow-fleet vectors before the January 20 transition. Subsequent enforcement and any rollback decisions fell to the incoming Trump administration.

The Bureau of Industry and Security (BIS) removed three persons from the Unverified List (UVL) effective January 19, 2024 because BIS was able to verify their bona fides pursuant to § 744.15(c)(2) of the EAR. The three removed parties are Skymount Drones (Canada), Plexus (Xiamen) Co., Ltd. (China), and Delma Industrial Supply & Marine Services (UAE). Removal restores eligibility for EAR license exceptions and removes the requirement for a signed UVL Statement before US exporters ship items subject to the EAR to these parties.

The Bureau of Industry and Security expanded EAR sanctions against Russia and Belarus effective 24 February 2023, adding 322 HTS-6 industrial items to Supplement No. 4 to Part 746 (oil-and-gas equipment, flat-rolled steel, pumps, turbines, marine and aviation engines) and 276 luxury goods to Supplement No. 5. Supplement No. 6 was amended to add biological and chemical-synthesis equipment including bioreactors, peptide synthesizers, and nucleotide reagents, targeting Russia's biodefence and dual-use procurement pathway. The rule also migrated Supplement No. 2 from Schedule B to HTS-6 identifiers to align with allied partner frameworks, added Taiwan to the list of countries excluded from licence requirements, and extended Section 744.7 end-use restrictions to cover in-country transfers inside Russia and Belarus.

BIS amends the Export Administration Regulations (EAR) to implement decisions reached at the Australia Group (AG) November 2021 and March 2022 Virtual Implementation Meetings and the July 2022 AG Plenary in Paris. The rule adds four marine toxins to ECCN 1C351.d (brevetoxins, gonyautoxins, nodularins, palytoxin), removes cholera toxin from the controlled list, updates plant pathogen nomenclature in 1C354 to reflect current taxonomy, and clarifies biological equipment definitions in ECCN 2B352 (medical isolator exclusions and the term "disinfected"). The changes align US controls with the current AG Common Control Lists without introducing new country-specific restrictions.

Effective 24 February 2022 — the date of Russia's full-scale invasion of Ukraine — the US Bureau of Industry and Security (BIS) published an interim final rule (87 FR 12226, FR Doc 2022-04300) adding sweeping new export license requirements under a new § 746.8 of the Export Administration Regulations (EAR). The rule requires a licence for any item in CCL Categories 3–9 (electronics, computers, telecommunications, sensors, lasers, navigation/avionics, marine, aerospace, propulsion) exported, reexported, or transferred to Russia, with a review policy of denial. Two new Russia-specific Foreign Direct Product (FDP) rules extend US jurisdiction to foreign-manufactured goods: the Russia FDP Rule (§ 734.9(f)) covers all foreign-made items using US technology/equipment destined for Russia, and the Russia-MEU FDP Rule (§ 734.9(g)) covers items destined to 47 designated military-end-user (MEU) entities with no licence exceptions available. All three restrictions carry a presumption of denial, making this the most sweeping peacetime expansion of the EAR since its modern codification.

The US Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 37 entities under 40 entries to the Entity List, effective December 17, 2021. The additions span three distinct threat rationales: (1) support for Chinese military modernization across semiconductors, submarine cables, armored vehicles, and defense electronics; (2) the Academy of Military Medical Sciences and 11 affiliated institutes pursuing biotechnology processes for military end uses, including purported brain-control weaponry under EAR §744.11(b); and (3) a cross-border Iran sanctions-evasion network operating across China, Georgia, Malaysia, and Turkey that diverted US-origin items to Iran's defense industries and advanced conventional weapons programs. All 40 entries carry a presumption-of-denial licensing policy for all items subject to the EAR, with no license exceptions available.

The Bureau of Industry and Security issued a final rule on September 11, 2020 amending the Export Administration Regulations (EAR) and Commerce Control List (CCL) to implement the remaining decisions adopted at the Wassenaar Arrangement December 2018 Plenary meeting, covering 28 ECCNs revised across Categories 1–3 and 5–9 and one new ECCN (6B002) added. The rule harmonises US dual-use export controls with the 41 other WA participating states, tightening or clarifying controls on semiconductors, sensors/lasers, navigation/avionics, marine equipment, aerospace propulsion, and information-security items. An earlier May 2019 rule had already implemented five emerging-technology decisions from the same 2018 Plenary; this rule covers the residual set of decisions not addressed at that time.